• NEWS
  • 1 SEPTEMBER 2020

Supreme Court confirms retroactive application of reduced transfer pricing penalties for fiscal years 2008 onwards

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Spyros Maratos

Spyros Maratos

Partner

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Dimitris Gialouris

Dimitris Gialouris

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Elina Filippou

Elina Filippou

Partner

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Elina Belouli

Elina Belouli

Associate

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Zepos & Yannopoulos successfully represented before the Supreme Administrative Court the Greek subsidiary of a leading international retail company in a transfer pricing dispute focusing on documentation related penalties. The Supreme Court confirmed that the currently applicable transfer pricing documentation rules are equivalent to the ones that applied since year 2008, under a regime that has since then been repealed (art. 26 Law 3728/2008). Therefore, the Supreme Court upheld that reduced transfer pricing documentation penalties set out in the currently applicable Law 4174/2013 may apply retroactively also with respect to disputes concerning fiscal years 2008-2010.

Leading lawyers: Spyros Maratos, Dimitris Gialouris, Elina Filippou and Elina Belouli